Written public comments for the draft Portland Plan must be submitted by December 28th. Bosco-Milligan Foundation executive director Cathy Galbraith presented testimony at a recent public hearing on the Portland Plan, expressing concern that nowhere in the document is the term historic preservation even mentioned. In fact, there is only one reference to “historic resources” to be found in the draft document – a big disappointment to those who have worked tirelessly over the past few years to keep the conversation about historic preservation moving forward.

In addition to concerns over the lack of mentioning historic preservation, here are some other excerpts from the Bosco-Milligan Foundation’s comments about the Portland Plan draft. Please consider sending your own comments to the city before the 12/28 deadline.

Entirely absent from the Plan is any acknowledgement of the existing Historic Resources Inventory

The issue of “community character” in the traditional neighborhoods is a concern that was raised time and time again in the earlier Portland Plan workshops. The omission of this concern throughout most of the Plan is an oversight that needs to be addressed now.

The Plan’s segment on Complete Neighborhoods cites (page 101) the need to “increase housing in areas with services” while ignoring the earlier description that these areas are primarily built out.

We do want Portland to at long last be a leader in social sustainability (page 10) – as important as and equal to environmental sustainability that has been the focus of much of the city’s efforts. Avoiding displacement and understanding and preserving historic and cultural connections should be an overriding goal of any equity agenda. The once-celebrated Albina Community Plan (1993) led to the start of displacement in N/NE; it was well-intentioned, but has long been described as “aspirational.” What’s relevant for the Portland Plan is that many of the lofty “action steps” that have gone unfulfilled in the Albina Community Plan read much like those in the proposed Portland Plan.

The Plan includes a city role in “helping to catalyze complementary local development” (page 25) for expansion of PCC Cascade, and “Develop new land use investment approaches to support the growth & neighborhood compatibility of college and hospital campuses in the comprehensive plan update” (page 47.) Our concern is the expansion through demolition and displacement that has been typically practiced by these institutions. A more important first step should be the public deliberation and adoption of institutional “master plans”, before it’s presumed that college and hospital campus expansions will be undertaken without detriment to the surrounding neighborhoods.

The historic preservation community, property owners in Portland’s Historic Districts, and developers are now assertively raising the issue of the city’s unreasonably high historic design review fees, in particular; the $3,000+ application fee for individual landmark designation has already proven to be a disincentive for designation, with a total of two such applications in the past nine years. Portland’s historic design review (and landmarks designation) fees are higher than all other Oregon jurisdictions and higher than for any comparably sizedmunicipality throughout the U.S.